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Patna High Court

Yasmeen KhatoonversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

Bail was granted to the petitioner subject to a bond and conditions under Section 480(3) of the BNSS.

Summary

The petitioner, Yasmeen Khatoon, sought bail in a case registered under Section 80(2) read with Section 3(5) of the Bharatiya Nyaya Sanhita, 2023, alleging her involvement in the death of the informant's sister. The prosecution alleged that the petitioner, as the mother‑in‑law of the deceased, participated in a dowry‑related killing motivated by a demand for a four‑wheeler. The petitioner contended she was falsely implicated, lived separately from the accused son, and had no role in the death, which was claimed to be a suicide. The State opposed bail, emphasizing the dowry‑death allegation. The court, noting the non‑specific nature of the allegations against a woman, the length of her custody, and the lack of direct evidence, granted bail on a bond of Rs.10,000 with two sureties and imposed standard conditions under Section 480(3) of the BNSS.

Issues considered

  • Whether bail should be granted to the petitioner under Section 80(2) r/w Section 3(5) of the Bharatiya Nyaya Sanhita, 2023 in view of the dowry‑death allegations.
  • Whether the allegations against the petitioner are specific enough to justify continued detention.

Legislation cited

Subjects

  • bail
  • dowry death
  • Section 80
  • Bharatiya Nyaya Sanhita
  • criminal procedure
  • women

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.6567 of 2026
                       Arising Out of PS. Case No.-77 Year-2025 Thana- Mission District- Sheikhpura
                 ======================================================
                 Yasmeen Khatoon Wife of Md. Akil Ahmad Resident of Mohalla- Mahallapar,
                 P.S.- Mission, District- Sheikhpura.

                                                                                     ... ... Petitioner/s
                                                         Versus
                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :         Mr. Satya Prakash Parasar, Advocate
                 For the Opposite Party/s :         Mr. Suman Kumari Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ARUN KUMAR JHA
                                       ORAL ORDER

2   04-02-2026                  Heard learned counsel for the petitioner and learned

                   APP for the State.

                                02. In the present case, the petitioner seeks bail in

                   connection with Mission P.S. Case No. 77 of 2025 registered on

                   13.12.2025 for the offences punishable under Section 80(2) r/w

                   Section 3(5) of Bharatiya Nyaya Sanhita, 2023.

                                03. As per prosecution case, the sister of the informant

                   was married with the son of the petitioner and allegation is that

                   the petitioner and other co-accused persons killed her on

                   account of their demand of a four wheeler for which she had

                   been continuously tortured.

                                04. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has been falsely implicated in this

                   case. The petitioner is the mother-in-law of the deceased and she
Patna High Court CR. MISC. No.6567 of 2026(2) dt.04-02-2026
                                            2/3




          resides separately from her co-accused son. The allegations are

          general and omnibus and whole family members have been

          roped in with the omnibus allegations. Learned counsel further

          submits that the sister of the informant committed suicide and

          the petitioner has no role in her death. Learned counsel further

          submits that the petitioner is in custody since 14.12.2025.

          Learned counsel also submits that the husband of the deceased

          has surrendered and, moreover, the alleged demand is of four

          wheeler for which the petitioner could not be a beneficiary.

                       05. Learned APP for the State opposes the submission

          made on behalf of the petitioner. Learned APP submits that the

          petitioner is mother-in-law of the deceased and there is

          allegation of causing dowry death of the sister of the informant.

                       06. Having regard to the facts and circumstances and

          submissions made on behalf of the parties and considering the

          fact that the petitioner is a lady and allegations are non-specific

          against her and further period of custody of the petitioner, she is

          directed to be released on bail on furnishing bail bonds of Rs.

          10,000/- (ten thousand) with two sureties of the like amount

          each to the satisfaction of learned Chief Judicial Magistrate,

          Shiekhpura/court concerned in connection with Mission P.S.

          Case No. 77 of 2025, subject to the conditions mentioned in
           Patna High Court CR. MISC. No.6567 of 2026(2) dt.04-02-2026
                                                       3/3




                     Section 480(3) of BNSS and the following conditions:

                                  (i) One of the bailors will be a close relative of

                                  the petitioner.

                                  (ii) The petitioner will remain present on each and

                                  every date fixed by the court below.

                                  (iii) In case of absence on three consecutive dates

                                  or in violation of the terms of the bail, the bail

                                  bond of the petitioner will be liable to be

                                  cancelled by the court concerned.



                                                       (Arun Kumar Jha, J)
Ashish/-

U      T


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